Jefferson Gas Coal Co. v. Commissioner of Internal Revenue

DAVIS, Circuit Judge.

This case arose out of the refusal of the Commissioner of Internal Revenue to allow as deduction in its income tax return $31,000 paid as so-called rentals, or minimum royalty, on coal mined and to be mined from lands leased to the petitioner for the years 1921,1922, and 1923, and out of his refusal to allow as a deduction the payment of a premium of $2,429.37 paid for the year 1921 on compensation insurance under the laws of Pennsylvania. The petitioner contends that the payments were ordinary and necessary expenses paid or incurred in the taxable years in carrying on…